ACE firmly agrees that the rate of the PV feed in tariff should be reduced in line with the reductions in the upfront cost of installing the technology. However, the speed with and degree to which the proposals cut the support is plainly irresponsible. The proposed cuts of over 50% for most domestic size installations are too significant to be responsibly introduced in one stage. Combined with the idiotically short timelines and retrospective application, the proposed reductions are the embodiment of bad policy making process.

ACE cannot state strongly enough that the proposed application of the new tariffs to installations with an eligibility date of 12 December, before the consultation is over let alone allowing for consideration of the responses, is completely unacceptable. One of the main purposes of the FIT was to create a market for renewable electricity technologies or further develop embryonic markets (such as for PV). The extreme and retrospective changes currently proposed will have the effect of immediately stalling investment, killing the burgeoning market developed over the previous 18 months and most importantly destroying industry confidence in this and other government schemes on which basis it is expected to invest.

The consultation does include are some excellent ideas which we would not like to lose. ACE firmly agrees with the proposal that eligibility for the tariff should be contingent on a minimum energy efficiency requirement being met. Further, ACE restates calls it has already made for renewable energy technologies to be financeable through Green Deal Finance and for the tariff payments to be included in the ‘savings’ side of the equation.